From the time the IRS disallows a taxpayer’s refund claim, the taxpayer has only two years to file a lawsuit in federal court. Similarly, the IRS has only two years to pay a refund after a disallowance. Accordingly, many...
Category: Blog
Federal tax law requires U.S. persons to report their international activities on information returns. With increasing globalization, more U.S. citizens and residents are finding themselves in the IRS’s crosshairs...
The Fifteenth Court of Appeals Holds that Returnable Containers May Qualify for the Manufacturing Exemption Creating Potential Opportunities for Refund Claims
February 16, 2026
It may not be polite to say we told you so, but we did. The authors of this article have long predicted the eventual demise of a 1980’s court decision that, like a few other relics from that decade (e.g., cassette tapes and...
Navigating the Federal Tax Consequences on Settlements and Judgments
February 6, 2026
The federal income tax consequences associated with litigation and settlements can be complex. From the plaintiff’s perspective, primary concerns are whether any payments received are taxable and, if so, whether the...
Introduction Under the Bank Secrecy Act (BSA), U.S. persons must generally file annual information returns to report their foreign accounts. Known as FBARs, these returns provide the government with specifics concerning the...